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CSS Solution Silverfinch Welcomes TISA & PIMFA MiFID II Initiative

In late June, PIMFA, the UK wealth management association and TISA, the Tax Investment and Savings association published the “MiFID II Feedback Template,” to be known as the EFT. They also published a “Distributor Reporting Guide” to assist firms with implementation and understanding. The two together are the first steps in defining a reporting standard … Continued

Do your Fund Documents Clearly Disclose Receipt of Accelerated Monitoring Fees?

Somewhat more reminiscent of the broken-windows enforcement era, two affiliated private equity advisers managing billions settled with the SEC on charges that they failed to make pre-commitment disclosures in fund governing documents related to accelerated fees received from portfolio companies. Interestingly, according to the Settlement Order, the advisers had made some disclosures in fund documents … Continued

With New Risk Alert, SEC Doubles Down on Best Execution

On July 11, 2018, the SEC issued a Risk Alert outlining commonly found compliance issues related to best execution by investment advisers. Advisers have an obligation to seek best execution of client transactions, taking into consideration quantitative factors such as execution quality and commission rate, as well as more qualitative factors such as the value … Continued